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I O W A 2008 TSI Pipeline Safety Conference

I O W A 2008 TSI Pipeline Safety Conference. West Des Moines, Iowa August 19-21, 2008 Donald J. Stursma, P.E. Manager, Safety & Engineering Section IOWA UTILITIES BOARD 515-281-5546 don.stursma@iub.state.ia.us. Iowa Utilities Board Pipeline Safety Staff. Cynthia Munyon Jeff O’Neal Reed Helm

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I O W A 2008 TSI Pipeline Safety Conference

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  1. IOWA2008 TSI Pipeline Safety Conference West Des Moines, Iowa August 19-21, 2008 Donald J. Stursma, P.E.Manager, Safety & Engineering SectionIOWA UTILITIES BOARD515-281-5546don.stursma@iub.state.ia.us

  2. Iowa Utilities BoardPipeline Safety Staff Cynthia Munyon Jeff O’Neal Reed Helm John Bloome Gary Burnett Larry Sorensen Duane Fournier ?

  3. WHAT’S HE GONNA TALK ABOUT? • DIMP • Mandatory Excess Flow Valves • 80% SMYS • Damage Prevention/One-Call Issues • Federal Reports and Follow-Up Issues • Etc.

  4. Distribution Integrity Management Plans (DIMP) DIMP rules required by the “Pipeline Inspection, Protection, Enforcement, and Safety Act of 2006” (PIPES Act) Work was in progress long before that Proposed rules published in Federal Register June 25, 2008 Are not what I was expecting Read, study, file comments if you want to have a say. Instructions in rulemaking. Deadline September 23, 2008.

  5. Mandatory EFVs Required by PIPES Act. Not mandatory yet - Original due date June 1, 2008. Now will be effective when DIMP rules final. Most Iowa operators already installing. May as well start now. Law also requires operators annually report number of EFVs installed.

  6. Operating at 80% SMYS • Proposed rules would allow SELECT pipelines to operate at 80% SMYS (current limit 72%) • Nothing magic about 72%. ANSI B31.8 and other countries allow 80% • Proposed rules set very high bar for 80% (about as complex as IMP rules, but different) • Final rule expected soon.

  7. One Call Enforcement Anything to do with damage prevention got a lot of support in testimony and from Congress. Strong enforcement of state one-call laws was hailed as an effective way to reduce dig-ins and incidents. Law says if PHMSA finds state enforcement is inadequate, PHMSA can take enforcement action against excavators (and operators are excavators too) who – Do not follow state one-call laws Do not respect marks Do not report damage to operator and 911 Also says PHMSA can take enforcement action against operators who do not respond to locate requests or do not mark accurately. (Does not require a finding that state enforcement is inadequate.)

  8. Dig-In Response Federal law includes new requirement to promptly report damage to the pipeline owner/operator and, if product released, call 911. (49 USC § 60114) Iowa law says that if you damage something you must notify the operator, and if an emergency results “immediately contact the operator and the appropriate authorities and necessary emergency response agencies.” (Iowa Code § 480.5) It is recommended you include calling 911 in your procedures and in your excavator training.

  9. State Damage Prevention Programs Congress and PHMSA are upping the ante on their expectations for state damage prevention/one-call programs. Want to see involvement, enforcement, and performance data. IUB asks for comments on Iowa’s one call system during inspections – everything is fine, right? No current initiative for new Iowa laws/rules on damage prevention. But watching federal developments.

  10. New Incident Report Forms PIPES Act said: SEC. 15. INCIDENT REPORTING. Not later than December 31, 2007, the Secretary of Transportation shall review the incident reporting requirements for operators of natural gas pipelines and modify the reporting criteria as appropriate to ensure that the incident data gathered accurately reflects incident trends over time, taking into consideration the recommendations from the Comptroller General in GAO report 06–946. and SEC. 20. ACCIDENT REPORTING FORM. Not later than December 31, 2007, the Secretary of Transportation shall amend accident reporting forms to require operators of gas and hazardous liquid pipelines to provide data related to controller fatigue.

  11. New Incident Report Forms • GAO report 06–946found: • Reporting of incident cause is inconsistent • $50,000 damage report threshold does not reflect recent increases in the price of natural gas. • That report was on transmission pipeline Integrity Management. • The controller fatigue issue appears primarily relevant to large transmission • but could be applied to the distribution form as well. • Other reports have been critical of distribution incident reporting, so OPS • is expected to revise that form too. • NPRM proposing new forms expected soon. • Expect much longer, more complicated forms. • File comments if you don’t like what you see!

  12. PHMSA Annual and Other Reports Some operators have not been submitting annual reports to PHMSA. Required by federal regulation in 49 CFR Part 191. Forms and instructions available at http://ops.dot.gov/library/forms/forms.htm Reports can be mailed, faxed, or sent electronically. IUB now checking during inspections if report filed. Some operators not sending a copy of federal reports to the IUB. Required by IUB rule. IUB now checking if we got these. If sent to OPS electronically we do NOT automatically get a copy. Some operators are not putting their 5-digit federal ID numberon reports filed with PHMSA. After IUB Public Awareness Plan work everybody should have one. If you need a number see website instructions or call (202) 366-8075 IUB now checking during inspections if OpID number is used.

  13. Speaking of Public Awareness Plans - In 2007-2008 IUB worked with PHMSA clearinghouse to insure plans met minimum requirements. IUB inspections will be looking at if you are doing what you plan says you will do.

  14. Check Address for Mailing Reports PHMSA has moved! New report address according to 49 CFR § 191.7 Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration PHP-10, 1200 New Jersey Avenue SE Washington DC 20590 May not be exactly the same on report instructions, but either should work. If your address book still says 400 7th Street SW, it’s wrong!

  15. If you file a federal incident report - Be sure to eventually file a FINAL report (check the box) Federal case file will remain open until a final report is received. PHMSA has been following up to close old files.

  16. About Telephonic Reports to IUB - Reporting requirements now in Rule 199 IAC § 19.17. When to report has not changed – how to report has. Now call the IUB Duty Officer at 515-745-2332. Number answered 24/7 (but mean it) IUB Safety & Engineering would also appreciate a call. More info/updates can go to IUBDutyOfficer@iub.state.ia.us And to me. If you make a telephonic report to the National Response Center be sure to call the IUB also!

  17. Electronic News IUB Safety & Engineering is working on putting inspection and permit records in electronic format. Will make information easier to retrieve and organize. IUB is moving towards an electronic filing system. Will make information on all IUB formal cases available online.

  18. Keep Don Happy When responding to an inspection report, please say in the letter who the inspector was. (Spare him the agony of looking it up.)

  19. QUESTIONS???

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